Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT allowed the assessee's appeal against denial of corpus donation exemption under section 11. The AO had denied the exemption and passed an assessment order under s.143(3) merely three days after issuing a show cause notice. The Tribunal noted that the assessee had filed a revised Form 10 on 21.04.2021, shortly after the assessment order dated 16.04.2021. Relying on Shri Chandraprabhuji Maharaj Jain, where it was held that no statutory time limit exists for filing Form 10, the ITAT set aside the CIT(A)'s order and remanded the matter to the AO with directions to consider the revised Form 10 accompanied by Board Resolution and decide on merits.
The ITAT allowed the assessee's appeal against denial of corpus donation exemption under section 11. The AO had denied the exemption and passed an assessment order under s.143(3) merely three days after issuing a show cause notice. The Tribunal noted that the assessee had filed a revised Form 10 on 21.04.2021, shortly after the assessment order dated 16.04.2021. Relying on Shri Chandraprabhuji Maharaj Jain, where it was held that no statutory time limit exists for filing Form 10, the ITAT set aside the CIT(A)'s order and remanded the matter to the AO with directions to consider the revised Form 10 accompanied by Board Resolution and decide on merits.
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